Income Tax Appellate Tribunal - Delhi
Antal Expo Fab Private Limited,Delhi vs Dcit Central Circle-5 Delhi, Delhi on 6 April, 2026
IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI 'C' BENCH,
NEW DELHI
BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER, AND
SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER
ITA No. 407/DEL/2026 [A.Y. 2018-19]
ITA No. 408/DEL/2026 [A.Y. 2019-20]
Antal Expo Fab Pvt. Ltd. Vs. The Dy. C.I.T
BD-22A, First Floor, BD Block, Central Circle-5
Sombazar Road, Near Mountabu Delhi
School, Shalimar Bagh,
Delhi - 110 088
PAN - AAPCA 4837 P
And
ITA No. 412/DEL/2026 [A.Y. 2018-19]
ITA No. 413/DEL/2026 [A.Y. 2019-20]
Mayank Aggarwal Vs. The Dy. C.I.T
BD-22A, First Floor, BD Block, Central Circle-5
Sombazar Road, Near Mountabu Delhi
School, Shalimar Bagh,
Delhi - 110 088
PAN - AUSPA 8533 G
And
ITA No. 458/DEL/2026 [A.Y. 2018-19]
ITA No. 459/DEL/2026 [A.Y. 2019-20]
Pujit Fashion Hub Pvt. Ltd. Vs. The Dy. C.I.T
BD-22A, First Floor, BD Block, Central Circle-5
Sombazar Road, Near Mountabu Delhi
School, Shalimar Bagh,
Delhi - 110 088
PAN - AAJCP 1749 H
(Applicant) (Respondent)
ITA Nos.407 & 408/DEL/2026 (Antal Expo Fab Pvt. Ltd. - A.Ys. 2018-19 & 2019-20)
ITA Nos.412 & 413/DEL/2026 (Manyank Aggarwal - A.Ys. 2018-19 & 2019-20)
ITA Nos.458 & 459/DEL/2026 (M/s. Pujit Fashion Hub Pvt. Ltd. - A.Ys. 2018-19 & 2019-20)
Assessee By : Shri Amit Kumar, Adv
Department By : Shri Dayainder Singh Sidhu, CIT-DR
Date of Hearing : 06.04.2026
Date of Pronouncement : 06.04.2026
ORDER
PER NAVEEN CHANDRA, ACCOUNTANT MEMBER :
The above captioned six appeals by the three different assessees are preferred against the order of the ld. Commissioner of Income Tax (Appeals) - 24, New Delhi dated 08.12.2025 arising from the assessment order dated 24.03.2023 (Mayank Aggarwal for A.Ys. 2018-19 & 2019-20) & dated 23.03.2023 (Antal Expo Fab Private Ltd. & Pujit fashion Hub Pvt. Ltd. for A.Ys. 2018-19 & 2019-20) under section 153C of the Act passed by the Assistant Commissioner of Income Tax, Central Circle - 5, Delhi pertaining to Assessment Years 2019-20, respectively.
2. Since the above captioned appeals were heard together and the facts in issues are identical, all these appeals are being disposed off by this common order for the sake of convenience and brevity. We take the ITA 407/Del/2026 in the case of Antal Expo Fab Pvt Ltd as the lead case. ITA No.407/Del/2026 for A.Y. 2018-19 (Antal Expo Fab Pvt Ltd)
3. The assessee has raised the following grounds of appeal: Page 2 of 13
ITA Nos.407 & 408/DEL/2026 (Antal Expo Fab Pvt. Ltd. - A.Ys. 2018-19 & 2019-20) ITA Nos.412 & 413/DEL/2026 (Manyank Aggarwal - A.Ys. 2018-19 & 2019-20) ITA Nos.458 & 459/DEL/2026 (M/s. Pujit Fashion Hub Pvt. Ltd. - A.Ys. 2018-19 & 2019-20)
1. Additional ground - The Ld. CIT(A)-24 has erred in law as well as on facts in confirming the assessment order u/s 153C passed by Central Circle-5, Delhi, which was time barred as per time limit provided by first limb of clause (ii) of third proviso to section 153B(1), since A.O. of the searched party and assessee is the same.
2. The Ld. CIT(A)-24, has erred in law as well as on facts in confirming the assessment order u/s 153C passed by Central Circle-5, Delhi, based on the basis of omnibus satisfaction note without identifying year-wise incriminating material relatable to assessee, having no reference of any amount or year.
3. The Ld. CIT(A)-24 has erred in law as well as on facts in confirming the assessment order u/s 153C passed by Central Circle-5, Delhi, based on the basis of consolidated mechanical approval from Addl. Commissioner of Income Tax, Central Range-02, New Delhi, dated 21.03.2023.
4. The Ld. CIT(A)-24 has erred in law as well as on facts in confirming the assessment order passed by Central Circle-5, Delhi, in which addition u/s 68 was made ignoring the fact that the presumption u/s 292C applies to the assessee when the incriminating material is found in his possession and not in the possession with a third party.
5. The Ld. CIT(A)-24 has erred in law as well as on facts in confirming the assessment order passed by Central Circle-5, Delhi, in which the addition u/s 68 was made based solely on information contained in A-
1/Busy Win/data2/Comp0004 collected from search of Shri Sumit Jindal and solely on the basis of his statement.
6. The Ld. CIT(A)-24 has erred in law as well as on facts in confirming the assessment order passed u/s 153C by Central Circle-5, without providing copy of statements of Shri Manish Gupta And Sushil Arora mentioned in para 6 on page 3 of Panchnama, copy of search warrant of Shri Sumit Jindal, Copy of seized data, copy of satisfaction note, copy of statement of Shri Sumit Jindal.
7. The Ld. CIT(A)-24 has erred in law as well as on facts in confirming the assessment order passed by Central Circle-5 in which total income of the Appellant was computed at Rs.66,12,041/- by making an addition of Rs.50,95,818/- u/s 68 for the alleged purchases made by assessee.
8. The Ld. CIT(A)-24 has erred in law as well as on facts in confirming the assessment order passed by Central Circle-5 in which addition of Rs. Rs.7,643/- (i.e. 0.15% of Rs.50,95,818/-) was made u/s 69C alleging that assessee has paid this commission for availing accommodation entries.
9. The Ld. CIT(A)-24 has erred in law as well as on facts in confirming the assessment u/s 153C by Central Circle-5, Delhi, made without making any independent inquiry u/s 133(6) or u/s 131(1).
10. The Ld. CIT(A)-24 has erred in law as well as on facts in confirming the assessment order passed by the Central Circle-5, Delhi, in which addition for purchases was made u/s 68, violating section 92 of evidence Act i.e. ignoring written evidence by oral allegations. Page 3 of 13
ITA Nos.407 & 408/DEL/2026 (Antal Expo Fab Pvt. Ltd. - A.Ys. 2018-19 & 2019-20) ITA Nos.412 & 413/DEL/2026 (Manyank Aggarwal - A.Ys. 2018-19 & 2019-20) ITA Nos.458 & 459/DEL/2026 (M/s. Pujit Fashion Hub Pvt. Ltd. - A.Ys. 2018-19 & 2019-20)
11. The Ld. CIT(A)-24 has erred in law as well as on facts in confirming the assessment order passed u/s 153C by Central Circle-5, relying only on statement of Shri Sumit Jindal u/s 131, to make additions of Rs.51.03 lakhs to the income of the assessee without giving opportunity of cross examination.
12. The Ld. CIT(A)-24 has erred in law as well as on facts in confirming the assessment order u/s 153C passed by Central Circle-5, without providing the copy of certificate obtained u/s 65B(4) of the Indian Evidence Act, 1872 for relying on seized material in the form of soft data. (Para 5 line 11 of Assessment Order)
13. The Ld. CIT(A)-24 has erred in law as well as on facts in confirming the addition made in the assessment order passed by Central Circle-5 without telling that what else the assessee should give in evidence to prove the genuineness of the transactions.
14. The Ld. CIT(A)-24 has erred in law as well as on facts in confirming the assessment order passed by Central Circle-5, by issuing notice u/s153C. No notice can be issued u/s 153C after 01.04.2021 for all the assessment years in terms of sub section (3) of section 153C.
15. The Ld. CIT(A)-24 has erred in law as well as on facts in confirming the assessment u/s 153C completed by Central Circle-5, as there was inordinate delay of near about three years in recording satisfaction u/s 153C i.e. after near about 3 years and completing the assessment after near about more than four years from date of search.
16. The Ld. CIT(A)-24 has erred in law as well on facts in confirming the order passed by Central Circle-5, Delhi by levying interest under section 234A, 234B and 234C of the Act.
17. The Ld. CIT(A)-24 has erred in law as well on facts in confirming the order passed by Central Circle-5 by initiating penalty proceedings under section 271AAC of the Act.
18. That the Appellant craves leave to add, alter, amend or vary from the aforesaid grounds of appeal at or before the time of hearing."
4. Brief facts of the case is that assessee is a Pvt. Ltd. company, incorporated on 21.04.2017 having two directors Pawan Kumar and Kusum Lata. The assessee is engaged in the business of cloth, both as retailer and whole seller. The assessee has filed its return of income u/s 139 of the Act, on 04.09.2018 declaring an income of Rs.15,05,580/-. Page 4 of 13
ITA Nos.407 & 408/DEL/2026 (Antal Expo Fab Pvt. Ltd. - A.Ys. 2018-19 & 2019-20) ITA Nos.412 & 413/DEL/2026 (Manyank Aggarwal - A.Ys. 2018-19 & 2019-20) ITA Nos.458 & 459/DEL/2026 (M/s. Pujit Fashion Hub Pvt. Ltd. - A.Ys. 2018-19 & 2019-20)
5. There was a search and seizure operation u/s 132 on Hawala Traders Group led by Sumit Jindal on 31.10.2018. From the premises of the said Sumit Jindal, certain incriminating material pertaining/relating to the assessee was found and seized. The assessee was accordingly issued notice u/s 153C dated 14.07.2021. In response to the notice issued u/s 153C of the Act, the assessee filed ITR declaring taxable income at Rs. 15,08,580/-on 14.10.2021.
6. During the course of assessment proceedings, it is found that the assessee has made non-genuine purchases to the tune of Rs.50,95,818/- from the entity M/s Puspdant Trading Co, managed and operated by Shri Sumit Jindal. The AO considered the entire such purchase as bogus and added the same u/s 68 of the Act vide assessment order dated 23.03.2023. The assessee's appeal before the Ld CIT(A) was dismissed on both legal as well as on merits. The aggrieved assessee is therefore before us.
7. At the outset, the assessee vehemently argued on the additional ground with regard to validity of assessment order passed under section 153C of the Act as being time barred and the satisfaction note being defective on account of omnibus satisfaction note without identifying year-wise incriminating material relatable to the assessee, having no Page 5 of 13 ITA Nos.407 & 408/DEL/2026 (Antal Expo Fab Pvt. Ltd. - A.Ys. 2018-19 & 2019-20) ITA Nos.412 & 413/DEL/2026 (Manyank Aggarwal - A.Ys. 2018-19 & 2019-20) ITA Nos.458 & 459/DEL/2026 (M/s. Pujit Fashion Hub Pvt. Ltd. - A.Ys. 2018-19 & 2019-20) reference of any amount or year. The ld AR contended that such a satisfaction note is not a valid satisfaction note which vitiated the assessment made under section 153C of the Act. The ld AR relied on the following decisions:
1. DCIT v Sunil Kumar Sharma [2025] 180 taxmann.com 293(SC) dated 27.10.2025 (Consolidated)
2. Rakesh Trisal vs DCIT Central Circle -27, Delhi dated 26.02.2026 ITA ITA No. 5760/DEL/2025 and No. 5761/DEL/2025 (Consolidated Satisfaction Note)
3. Seema Agarwal vs DCIT Central Circle -27, Delhi dated 26.02.2026 ITA ITA No. 5979-5981/Del/2025 (Consolidated satisfaction note)
4. Praveen Garg vs DCIT (ITA No. 5994/Del/2025) dated 25.02.2026 (Consolidated satisfaction note)
5. Sh. Sudesh Gahlot vs DCIT ITA No. 4338/Del/2025 dated 20.02.2026 (Consolidated)
6. Shyam Gupta vs DCIT(ITA No's 3134 to 3137/Del/2025) dated 25.02.2026 (Defective Satisfaction note)
7. ACIT vs Kishore Kumar Sharma [2025] 178 taxmann.com 661 (SC) dated 04.09.2025 (Defective Satisfaction note)
8. Per contra, Learned DR Relied on the orders of the AO and CIT(A).
9. We have heard the rival submissions and perused the material available on record. As the common additional legal ground taken by the assessee relates to validity of Satisfaction note, we admit the same in the light of the hon'ble Supreme Court judgement in the case of National Thermal Power Co Ltd (1998) 229 ITR 383(SC).
10. To adjudicate on the issue, we deem it appropriate to reproduce the satisfaction notes, recorded by the assessing officer of the searched person Sumit Jindal as well as person 'other than the person searched' Page 6 of 13 ITA Nos.407 & 408/DEL/2026 (Antal Expo Fab Pvt. Ltd. - A.Ys. 2018-19 & 2019-20) ITA Nos.412 & 413/DEL/2026 (Manyank Aggarwal - A.Ys. 2018-19 & 2019-20) ITA Nos.458 & 459/DEL/2026 (M/s. Pujit Fashion Hub Pvt. Ltd. - A.Ys. 2018-19 & 2019-20) u/s 153C i.e., all the present assessees namely, Mayank Agarwal; Antal Expo Fab Pvt Ltd and Pujit Fashion Hub Pvt Ltd, before us as follows:
13.07.2021 (Shri Gopal Textiles, Prop Sh. Mayank Aggarwal) (PAN-AUSPA 8533 G) Satisfaction Note with regard to documents and other materials found and seized during the search and seizure proceedings at the premises of Sh. Sumit Jindal at Room No 212, 2605, 2nd floor, Naya Bazar, Delhi Date of search-31.10.2018 A search and Seizure action u/s 132 of the Act was conducted on 31.10.2018 in the case of Sh. Sumit Jindal at Room No 212, 2605, 2nd floor, Naya Bazar, Delhi. On perusal of the Busy Win data seized as Annexure of A I it is noticed that information contained in A-1/Busy Win/Data2/Comp0004 relates to Shri Gopal Textiles. Information contained in soft data present in the above hard disk as Busy Win and other documents also relates to Shri Gopal Textiles.
A careful analysis of seized documents and provisions of section 153C of the Act, I am satisfied that these documents relate to Shri Gopal Textiles and the information contained in the documents also relates to the company also.
Sd/-
DCIT CC-05, New Delhi (AO of the search person u/s 132 of the Act 13.07.2021 (Shri Gopal Textiles, Prop Mayank Agarwal) (PAN-AUSPA8533G) Satisfaction Note for proceedings u/s 153C of the Income Tax Act, 1961 Digital data seized as Annexure A-1 during search u/s132 of the Act and received from the assessing officer of searched person Sh. Sumit Jindal have been examined. After examination of such soft data I am satisfied that the above data have a bearing on the determination of the total income of Shri Gopal Textiles.
Therefore, I am satisfied that Shri Gopal Textiles is covered u/s 153C of the Act. Accordingly, notices u/s 153C of the Act, are issued for AY 2013-14 to 2019-20.
Sd/-
Page 7 of 13 ITA Nos.407 & 408/DEL/2026 (Antal Expo Fab Pvt. Ltd. - A.Ys. 2018-19 & 2019-20) ITA Nos.412 & 413/DEL/2026 (Manyank Aggarwal - A.Ys. 2018-19 & 2019-20) ITA Nos.458 & 459/DEL/2026 (M/s. Pujit Fashion Hub Pvt. Ltd. - A.Ys. 2018-19 & 2019-20) DCIT CC-05, New Delhi (AO of 'any other person' as per the section 153C of the Act ) 13.07.2021 M/s Antal Expo Fab Pvt Ltd (AAPCA4837P) Satisfaction Note with regard to documents and other materials found and seized during the search and seizure proceedings at the premises of Sh. Sumit Jindal at Room No 212, 2605, 2nd floor, Naya Bazar, Delhi Date of search-31.10.2018 A search and Seizure action u/s 132 of the Act was conducted on 31.10.2018 in the case of Sh. Sumit Jindal at Room No 212, 2605, 2nd floor, Naya Bazar, Delhi. On perusal of the Busy Win data seized as Annexure of A I it is noticed that information contained in A-1/Busy Win/Data2/Comp0004 relates to M/s Antal Expo Fab Pvt Ltd (AAPCA4837P). Information contained in soft data present in the above hard disk as Busy Win and other documents also relates to Shri Gopal Textiles.
A careful analysis of seized documents and provisions of section 153C of the Act, I am satisfied that these documents relate to M/s Antal Expo Fab Pvt Ltd (AAPCA4837P) and the information contained in the documents also relates to the company also.
Sd/-
DCIT CC-05, New Delhi (AO of the search person u/s 132 of the Act 13.07.2021 M/s Antal Expo Fab Pvt Ltd (AAPCA4837P) Satisfaction Note for proceedings u/s 153C of the Income Tax Act, 1961 Digital data seized as Annexure A-1during search u/s132 of the Act and received from the assessing officer of searched person Sh. Sumit Jindal have been examined. After examination of such soft data I am satisfied that the above data have a bearing on the determination of the total income of M/s Antal Expo Fab Pvt Ltd.
Therefore, I am satisfied that M/s Antal Expo Fab Pvt Ltd is covered u/s 153C of the Act. Accordingly, notices u/s 153C of the act, are issued for ΑΥ 2013-14 tο 2019-20.
DCIT CC-05, New Delhi (AO of 'any other person' as per the section 153C of the Act) Page 8 of 13 ITA Nos.407 & 408/DEL/2026 (Antal Expo Fab Pvt. Ltd. - A.Ys. 2018-19 & 2019-20) ITA Nos.412 & 413/DEL/2026 (Manyank Aggarwal - A.Ys. 2018-19 & 2019-20) ITA Nos.458 & 459/DEL/2026 (M/s. Pujit Fashion Hub Pvt. Ltd. - A.Ys. 2018-19 & 2019-20) 13.07.2021 M/s Pujit Fashion Hub Pvt Ltd (AAJCP1749H) Satisfaction Note with regard to documents and other materials found and seized during the search and seizure proceedings at the premises of Sh. Sumit Jindal at Room No 212, 2605, 2nd loot, Naya Bazar, Delhi Date of search-31.10.2018 A search and Seizure action u/s 132 of the Act was conducted on 31.10.2018 in the case of Sh. Sumit Jindal at Room No 212, 26/15, 2nd floor. Naya Bazar, Delhi. On perusal of the Busy Wim data seized as Annexure of 1 is noticed that information contained in A-1/Busy Win/Data2/Comp relates to M/s Pujit Fashion Hub Pvt. Ltd. Information contained in soft data present in the above hard disk as Busy Win and other documents also relates to M/s Pujit Fashion Hub Pvt. Ltd. A careful analysis of seized documents and provisions of section 153C of the Act, I am satisfied that these documents relate to M/s Pujit Fashion Hub Pvt. Ltd and the information contained in the documents also relates to the company also.
sd/-
DCIT CC-05. New Delhi (AO of the search person u/s 132 of the Act 13.07.2021 M/s Pujit Fashion Hub Pvt Ltd (AAJCP1749H) Satisfaction Note for proceedings u/s 153C of the Income Tax Act, 1961 Digital data seized as Annexure A-1during search u/s132 of the Act and received from the assessing officer of searched person Sh. Sumit Jindal have been examined. After examination of such soft data I am satisfied that the above data have a bearing on the determination of the total income of M/s Pujit Fashion Hub Pvt Ltd (AAJCP1749H). Therefore, I am satisfied that M/s Pujit Fashion Hub Pvt Ltd is covered u/s 153C of the Act. Accordingly, notices u/s 153C of the act, are issued for ΑΥ 2013-14 tο 2019-20.
DCIT CC-05, New Delhi (AO of 'any other person' as per the section 153C of the Act)
11. From the perusal of the above satisfaction notes by the assessing officer of the assessees, who are the person 'other than the searched Page 9 of 13 ITA Nos.407 & 408/DEL/2026 (Antal Expo Fab Pvt. Ltd. - A.Ys. 2018-19 & 2019-20) ITA Nos.412 & 413/DEL/2026 (Manyank Aggarwal - A.Ys. 2018-19 & 2019-20) ITA Nos.458 & 459/DEL/2026 (M/s. Pujit Fashion Hub Pvt. Ltd. - A.Ys. 2018-19 & 2019-20) person', we find that it is an omnibus satisfaction note which has not identified the year wise incriminating materials that pertains/relates to the assessee. The satisfaction note also doesn't record the amount of income that is proposed to be taxed as income of the assessee with reference to the assessment years to which the materials/documents pertain/relates to. It is also an uncontroverted fact, as reflected from the perusal of the satisfaction notes, that the AO has failed to record as to how the materials referred to by the AO of the searched person could "have a bearing on the determination of total income of such other person".
12. In such a factual matrix of the instant cases, we find that Hon'ble Supreme Court in the case of ACIT vs. Kishore Kumar Sharma reported in 178 taxmann.com 661 (SC) has dismissed the SLP filed by the Revenue against the Hon'ble Delhi Court decision reported in (2025) 178 taxmann.com 315(Delhi) wherein the hon'ble Delhi High Court had held that where the satisfaction note issued by Jurisdictional Assessing Officer of assessee did not refer to any incriminating material for relevant assessment years, it was ex facie evident that there were no incriminating material found for relevant assessment years. The hon'ble Court had further held that where the Jurisdictional Assessing Officer Page 10 of 13 ITA Nos.407 & 408/DEL/2026 (Antal Expo Fab Pvt. Ltd. - A.Ys. 2018-19 & 2019-20) ITA Nos.412 & 413/DEL/2026 (Manyank Aggarwal - A.Ys. 2018-19 & 2019-20) ITA Nos.458 & 459/DEL/2026 (M/s. Pujit Fashion Hub Pvt. Ltd. - A.Ys. 2018-19 & 2019-20) completely failed to record any reasons indicating how material referred to by Assessing Officer of searched person could "have a bearing on determination of total income of such other person", in such situation the notice issued under section 153C of the Act is rendered as invalid and liable to be quashed.
13. We find from the perusal of the satisfaction notes as reproduced above, that nowhere the Assessing Officer, having jurisdiction over the assessee, has recorded the details of incriminating materials for relevant assessment years and as to how the materials/documents seized have a bearing on determination of total income of the assessee. In view of the aforesaid decision of the hon'ble Delhi High Court, against which the SLP was dismissed by the Hon'ble Supreme Court, such satisfaction notes cannot be held as a valid satisfaction notes under the eyes of law and consequently, the same has vitiated the proceedings under section 153C of the Act. We are therefore of the considered view that the assessment made under section 153C of the Act are unsustainable in the eyes of law and therefore, quashed. The additional ground 2 of the appeal is allowed.
14. As the adjudication has been made on one of the legal grounds, the grounds on other legal as well as on merits is not adjudicated. Page 11 of 13
ITA Nos.407 & 408/DEL/2026 (Antal Expo Fab Pvt. Ltd. - A.Ys. 2018-19 & 2019-20) ITA Nos.412 & 413/DEL/2026 (Manyank Aggarwal - A.Ys. 2018-19 & 2019-20) ITA Nos.458 & 459/DEL/2026 (M/s. Pujit Fashion Hub Pvt. Ltd. - A.Ys. 2018-19 & 2019-20)
15. As the facts in ITA Nos.407 & 408/DEL/2026 (Antal Expo Fab Pvt. Ltd. -A.Ys. 2018-19 & 2019-20); ITA Nos.412 & 413/DEL/2026 (Manyank Aggarwal - A.Ys. 2018-19 & 2019-20); ITA Nos.458 & 459/DEL/2026 (M/s. Pujit Fashion Hub Pvt. Ltd. - A.Ys. 2018-19 & 2019-20) are identical, the decision rendered in ITA 407/Del/2026 in the case of Antal Expo Fab Pvt shall apply mutatis mutandis to other cases as well.
16. In the result, appeal of the assessee in ITA Nos.407 & 408/DEL/2026; ITA Nos.412 & 413/DEL/2026; ITA Nos.458 & 459/DEL/2026 are allowed.
The order is pronounced in the open court on 06.04.2026.
Sd/- Sd/-
[SATBEER SINGH GODARA] [NAVEEN CHANDRA]
JUDICIAL MEMBER ACCOUNTANT MEMBER
Dated: 13th April, 2026.
Priti Yadav,Sr. Ps*
Copy forwarded to:
1. Assessee
2. Respondent
3. CIT
4. CIT(A) Asst. Registrar,
5. DR ITAT, New Delhi
Page 12 of 13